- 39 -                                         
          quantify or explain how he adjusted his analysis to take account            
          of that factor.  Indeed, such factor has recently been rejected             
          by the Court of Appeals for the Ninth Circuit, the likely venue             
          of any appeal in this case.  Estate of Simplot v. Commissioner,             
          249 F.3d 1191, 1195 (9th Cir. 2001), revg. 112 T.C. 130 (1999).             
          We did not find Dr. Spiro’s oral testimony to be persuasive.  It            
          did not bolster what we found to be weak analysis in his written            
          reports.                                                                    
               We found Dr. Bajaj’s analysis in support of his 25-percent             
          basic discount to be both thorough and convincing, and we find              
          that a basic discount for lack of marketability in the amount of            
          25 percent is appropriate.                                                  
                    d.  Additional Discounts                                          
                    (1)  Discount for Lack of Control                                 
               Dr. Bajaj describes his entire 35-percent discount as a                
          discount for lack of marketability.  We view his proposed                   
          discount for “agency problems”, however, as a discount for                  
          minority status (or lack of control), as it is based upon the               
          inability of the owner of the shares to force the majority                  
          shareholder, Gary Heck, to make dividend distributions.                     
          Dr. Bajaj’s discount for minority status takes into account                 
          factors similar to what Dr. Spiro took into account in addressing           
          problems associated with Korbel’s S corporation status, at least            
          to the extent that Dr. Spiro’s discount relates to the same lack            
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